Special thanks to Robert Mazur for the contributing editors piece.


I’ve had the privilege of working with journalists from the ICIJ, BuzzFeed and many other media outlets during the past decade. When approached a few months ago to analyze leaked SARs and offer my perspectives about the significance of the documents, I paused and consulted to ensure that I would not likely be opining about transactions that had occurred so recently that I might be undermining efforts within FinCEN or law enforcement to pursue ongoing crimes. Satisfied that wasn’t the case, I analyzed hundreds of pages for many days.

As time drew near publication, FinCEN suggested that sharing this information with the public could undermine national security, harm ongoing investigations, endanger the safety of witnesses, and chill the efforts of an otherwise spirited participation of institutions in the SAR process. In my view, the opposite is much more likely.

It is my hope that the facts publicized in many articles related to the FinCEN Files get a very thorough review by the Inspector General’s Office and Congress, so the public can be assured that the financial community, FinCEN, and law enforcement are all doing the maximum that can be done to most effectively serve the public through the SAR program.

In the days to come, with the permission of BuzzFeed, I will explain in greater detail the tragedy I witnessed in the FinCEN Files. In the meantime, here’s a link to the Buzzfeed article published today that addresses the issues I helped to analyze: